# FinCEN and OFAC propose GENIUS Act AML and sanctions programs for stablecoin issuers

> FinCEN and OFAC jointly proposed treating permitted payment stablecoin issuers as financial institutions under the BSA and requiring risk-based AML/CFT and sanctions compliance programs.

- URL: https://riadefi.com/regulation/2026-04-10-genius-act-fincen-ofac-aml-sanctions-proposal/
- Posture: Proposal · not in effect
- Authorities: Treasury Department; Foreign Assets Control Office; Financial Crimes Enforcement Network
- Event date: 2026-04-10
- Version: 1, published 2026-08-07 (first published 2026-08-07)
- Advisor-relevant: yes

This entry records a proposal. It does not change the law unless it is adopted.

## What changed

FinCEN and OFAC jointly proposed treating permitted payment stablecoin issuers as financial institutions under the BSA and requiring risk-based AML/CFT and sanctions compliance programs.

## Who it affects

- Permitted payment stablecoin issuers and advisers diligencing issuers or stablecoins

## What is still open

- The final program standards, effective date, and interaction with prudential-regulator rules

## What it means for an advisor

- Add the proposal to issuer and stablecoin due-diligence frameworks, but distinguish it from current obligations.

## Sources

1. [Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements](https://www.govinfo.gov/content/pkg/FR-2026-04-10/pdf/2026-06963.pdf) · Treasury Department; Foreign Assets Control Office; Financial Crimes Enforcement Network · 2026-04-10


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Published by Ketju Research on RIADeFi (https://riadefi.com). Educational research for financial professionals; not investment, legal, tax, or compliance advice.